Portugal

As a Member State of the European Union, Portugal is subject to accounting, auditing, and financial reporting requirements established through EU Regulations and Directives, as transposed into national law.

The Portuguese accounting framework is governed by the Sistema de Normalização Contabilística (SNC), established by Decree-Law No. 158/2009 and most recently amended by Decree-Law No. 73/2023. The Comissão de Normalização Contabilística (CNC), operating under the Ministry of Finance, is responsible for issuing accounting standards. The SNC establishes differentiated financial reporting requirements depending on the size and nature of the entity. These include specific standards for micro-entities, small and medium-sized entities, non-profit entities, and other non-listed entities. Although the SNC is based on IFRS, differences remain between national standards and IFRS as issued by the IASB. IFRS for SMEs has not been adopted in Portugal. Under certain circumstances, entities are permitted to apply IFRS for the preparation of consolidated financial statements.

Financial sector regulators are empowered to establish accounting and financial reporting requirements for entities under their supervision. Banco de Portugal oversees banks and other credit institutions, the Autoridade de Supervisão de Seguros e Fundos de Pensões supervises insurance undertakings and pension funds, and the Comissão do Mercado de Valores Mobiliários supervises listed companies and public interest entities. In accordance with Regulation (EC) No. 1606/2002, EU-endorsed IFRS are required for the consolidated financial statements of listed companies.

The Companies Code, enacted by Decree-Law No. 262/86 and subsequently amended, establishes general reporting obligations for all business entities, including the requirement to maintain accounting records and prepare annual financial statements.

Statutory audit requirements are established by Law No. 148/2015, as amended, which transposes Directive 2014/56/EU and incorporates Regulation (EU) No. 537/2014. The law requires statutory audits to be performed in accordance with International Standards on Auditing, as issued by the IAASB. The supervision of statutory auditors is carried out by the Comissão do Mercado de Valores Mobiliários, which acts as the independent public oversight authority.

The profession in Portugal is structured into two legally distinct segments. Statutory auditors are regulated by the Ordem dos Revisores Oficiais de Contas under Law No. 79/2023 and are subject to public oversight by the Comissão do Mercado de Valores Mobiliários. Chartered accountants are regulated by the Ordem dos Contabilistas Certificados under Law No. 68/2023. Chartered accountants are authorized to prepare and certify financial statements and tax returns but are not authorized to perform statutory audits.

In Portugal, the accountancy profession is divided into two legally distinct segments: statutory auditors (Revisores Oficiais de Contas, ROCs) and chartered accountants (Contabilistas Certificados, CCs). Each segment is regulated by a public professional body established by law and operating under the oversight of the Ministry of Finance.

Chartered accountants are regulated by the Ordem dos Contabilistas Certificados (OCC) in accordance with Law No. 68/2023. Membership in the OCC is mandatory for individuals providing accounting services, including the preparation and certification of financial statements and tax returns. To qualify as a Contabilista Certificado, candidates must hold a university degree in a business-related field corresponding to at least 180 ECTS credits, complete a period of supervised practical experience or demonstrate relevant professional experience as defined by law, and pass a professional examination or complete an approved modular training program with assessment. OCC members are subject to mandatory continuing professional development requirements, ethical standards, a quality assurance system, and an investigation and disciplinary system. The OCC is responsible for maintaining the registry of chartered accountants and accounting firms and for administering its regulatory functions.

Statutory auditors are regulated by the Ordem dos Revisores Oficiais de Contas (OROC) in accordance with Law No. 79/2023. To be admitted as a statutory auditor, candidates must hold a master’s degree, complete at least three years of supervised practical training, and pass a comprehensive examination process. Following admission to OROC, statutory auditors must be registered with the Comissão do Mercado de Valores Mobiliários (CMVM) in order to perform statutory audits. OROC is responsible for implementing initial and continuing professional development requirements, establishing ethical requirements, maintaining the registry of statutory auditors and audit firms, and administering quality assurance and investigation and disciplinary systems for non-public interest entity audits.

Public oversight of statutory auditors, particularly in respect of audits of public interest entities, is exercised by the Comissão do Mercado de Valores Mobiliários under Law No. 148/2015. The CMVM is responsible for registration, quality assurance inspections, and enforcement activities relating to public interest entity audits.

The responsibilities of the OCC do not extend to the regulation or oversight of statutory audit engagements.

In Portugal, statutory auditors and audit firms are subject to independent public oversight in accordance with Law No. 148/2015, which transposes Directive 2014/56/EU and incorporates Regulation (EU) No. 537/2014.

The Comissão do Mercado de Valores Mobiliários (CMVM) is designated as the independent public oversight authority. The CMVM is responsible for maintaining the public registry of statutory auditors and audit firms authorized to perform audits of public interest entities, conducting quality assurance inspections of public interest entity audits, carrying out investigations and enforcement actions, and issuing regulations within the scope of its mandate. The CMVM is a member of the International Forum of Independent Audit Regulators.

The Ordem dos Revisores Oficiais de Contas (OROC) carries out quality assurance reviews for non-public interest entity audits and administers investigation and disciplinary procedures for matters within its competence. OROC’s quality assurance system is subject to supervision by the CMVM to ensure consistency with public oversight requirements.

The Ordem dos Contabilistas Certificados does not have responsibility for statutory audit oversight.

Two professional accountancy organizations operate in Portugal: the Ordem dos Contabilistas Certificados (OCC) and the Ordem dos Revisores Oficiais de Contas (OROC). Both are established by law and operate under statutory mandates.

The Ordem dos Contabilistas Certificados (OCC), established in 1995 and currently governed by Law No. 68/2023, is the mandatory professional body for chartered accountants (Contabilistas Certificados) and accounting firms. The OCC is responsible for the regulation of its members, including admission requirements, continuing professional development, ethical standards, quality assurance, and investigation and disciplinary procedures. Chartered accountants are authorized to prepare and certify financial statements and tax returns but are not authorized to perform statutory audits. The OCC has been a full member of IFAC since 2016.

The Ordem dos Revisores Oficiais de Contas (OROC), established in 1974 and governed by Law No. 79/2023, is the mandatory professional body for statutory auditors (Revisores Oficiais de Contas) and audit firms. OROC regulates admission to the audit profession, continuing professional development, ethical requirements, quality assurance for non-public interest entity audits, and investigation and disciplinary procedures. Public oversight of statutory audit, particularly for public interest entities, is exercised by the Comissão do Mercado de Valores Mobiliários. OROC is also a full member of IFAC.

The responsibilities of the two organizations are clearly delineated by law, reflecting the dual structure of the Portuguese accountancy profession.

In Portugal, a mandatory quality assurance review system is required for all statutory audits in accordance with Law No. 148/2015, which transposes Directive 2014/56/EU and incorporates Regulation (EU) No. 537/2014.

Responsibility for quality assurance is shared between the Comissão do Mercado de Valores Mobiliários (CMVM) and the Ordem dos Revisores Oficiais de Contas (OROC). The CMVM, acting as the independent public oversight authority, conducts inspections of statutory auditors and audit firms performing audits of public interest entities. The CMVM operates a risk-based inspection system consistent with the requirements of EU audit reform legislation.

OROC conducts quality assurance reviews of statutory auditors and audit firms performing audits of non-public interest entities. The system includes cyclical inspections at both firm and engagement level, written inspection reports, defined reviewer qualification criteria, annual reviewer training requirements, and follow-up procedures where deficiencies are identified. OROC has translated and disseminated the International Standards on Quality Management and incorporated them into its inspection methodology. Its quality assurance procedures are subject to periodic review and operate under the supervision of the CMVM.

Based on available information, quality assurance systems incorporating the requirements of SMO 1 are established and operational for all statutory audits in Portugal.

Current Status: Adopted

In Portugal, the establishment and implementation of professional education requirements for accountants are shared among higher education institutions, the Ordem dos Contabilistas Certificados (OCC), and the Ordem dos Revisores Oficiais de Contas (OROC), under the legal framework established by Law No. 148/2015, Law No. 79/2023, and Law No. 68/2023.

For admission as a Contabilista Certificado, candidates must hold a university degree in a business-related field corresponding to at least 180 ECTS credits, complete a period of supervised practical experience or demonstrate relevant professional experience as defined by law, and pass a professional examination or complete an approved modular training program with assessment.

For admission as a statutory auditor, candidates must hold a master’s degree, complete a minimum of three years of supervised practical training, and pass a comprehensive professional examination process.

Both OCC and OROC members are subject to mandatory continuing professional development requirements. OCC requires a minimum of 30 hours of verifiable CPD annually, with monitoring and compliance mechanisms in place. OROC members are also subject to CPD requirements consistent with statutory obligations.

Based on available information, the initial and continuing professional development requirements applicable to professional accountants in Portugal are aligned with the 2019 International Education Standards, including requirements relating to entry, practical experience, professional competence, assessment, ethics, and continuing professional development.

Current Status: Adopted

In Portugal, statutory audit requirements are established by Law No. 148/2015, which transposes Directive 2014/56/EU and incorporates Regulation (EU) No. 537/2014. The law requires statutory audits to be performed in accordance with International Standards on Auditing, as issued by the International Auditing and Assurance Standards Board.

Responsibility for the regulation and implementation of ISA lies with the Ordem dos Revisores Oficiais de Contas (OROC), in coordination with the Comissão do Mercado de Valores Mobiliários for audits of public interest entities. OROC is responsible for the official translation and dissemination of the IAASB Handbook into Portuguese. The 2020 IAASB Handbook has been translated and made available to practitioners, and subsequent revisions are being incorporated in accordance with the established legal framework.

ISA are applied to all statutory audits in Portugal without national modification. Based on available information, ISA as issued by the IAASB are adopted and required by law for use in the jurisdiction.

The Ordem dos Contabilistas Certificados does not have responsibility for the adoption or implementation of auditing standards.

Current Status: Adopted

In Portugal, all professional accountants are subject to binding ethical requirements established by law and administered through their respective professional bodies.

For statutory auditors, the Ordem dos Revisores Oficiais de Contas (OROC) establishes ethical requirements in accordance with its statutory mandate. OROC maintains a Code of Ethics that incorporates the International Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants. Statutory auditors are therefore required to comply with ethical standards consistent with the IESBA Code.

For chartered accountants, ethical requirements are established through the Código Deontológico dos Contabilistas Certificados, which is approved under national legislative procedures. The Ministry of Finance is responsible for proposing the Code, which is subject to parliamentary approval and is binding on members of the Ordem dos Contabilistas Certificados (OCC). The national Code does not explicitly incorporate the IESBA Code by reference. While the OCC indicates that its ethical framework is substantively aligned with the 2023 edition of the IESBA Code, full formal adoption of the IESBA Code as issued has not been demonstrated.

Based on available information, the IESBA Code is incorporated for statutory auditors but not formally adopted for all professional accountants in the jurisdiction.

Current Status: Partially Adopted

In Portugal, responsibility for the development and issuance of public sector accounting standards lies with the Comissão de Normalização Contabilística (CNC), under the supervision of the Ministry of Finance, in accordance with Decree-Law No. 134/2012.

The public sector accounting framework, the Sistema de Normalização Contabilística para as Administrações Públicas (SNC-AP), was adopted through Decree-Law No. 192/2015. The SNC-AP is based on accrual accounting and was developed with reference to the 2014 version of the International Public Sector Accounting Standards.

While the SNC-AP is broadly aligned with IPSAS in structure and principles, it includes national standards that are not derived from IPSAS, including standards addressing budgetary and management accounting. Certain differences and adaptations also exist to reflect national legal and administrative requirements.

Based on available information, IPSAS as issued by the IPSASB are not adopted in their entirety in Portugal, and the national framework reflects partial convergence.

The Ordem dos Contabilistas Certificados does not have responsibility for public sector standard setting but participates in consultation and training activities relating to the implementation of the SNC-AP.

Current Status: Partially Adopted

In Portugal, professional accountants are subject to legally established investigation and disciplinary systems applicable to both statutory auditors and chartered accountants.

For chartered accountants, the Ordem dos Contabilistas Certificados (OCC) operates an investigation and disciplinary system in accordance with Law No. 68/2023. The framework defines professional misconduct, establishes investigative and adjudicative bodies, and provides procedural safeguards including the right to be heard, representation, and appeal. Sanctions range from reprimand to suspension or expulsion, depending on the severity of the infraction. Disciplinary decisions may be published in accordance with applicable legal provisions.

For statutory auditors, the investigation and disciplinary framework is established under Law No. 148/2015 and the Statute of the Ordem dos Revisores Oficiais de Contas. Responsibility is shared between the Comissão do Mercado de Valores Mobiliários (CMVM) and the Ordem dos Revisores Oficiais de Contas (OROC). The CMVM exercises enforcement authority in relation to audits of public interest entities, while OROC retains responsibility for disciplinary matters relating to non-public interest entity audits and other professional breaches within its mandate.

Based on available information, Portugal has established legally enforceable investigation and disciplinary systems for all professional accountants that incorporate key elements of SMO 6, including defined misconduct, independent processes, graduated sanctions, and rights of appeal.

Current Status: Adopted

In Portugal, International Financial Reporting Standards as endorsed by the European Union are required for the preparation of consolidated financial statements of listed companies in accordance with Regulation (EC) No. 1606/2002. EU-endorsed IFRS are therefore mandatory for public interest entities that are subject to capital market regulation.

Sectoral regulators, including Banco de Portugal, the Autoridade de Supervisão de Seguros e Fundos de Pensões, and the Comissão do Mercado de Valores Mobiliários, require EU-endorsed IFRS for consolidated financial reporting within their respective areas of supervision. The application of IFRS to individual financial statements is permitted in certain circumstances, subject to legal and regulatory provisions.

For entities that are not required to apply IFRS, accounting standards are established by the Comissão de Normalização Contabilística under Decree-Law No. 134/2012. The national accounting framework, the Sistema de Normalização Contabilística, is based on IFRS principles but is adapted to national legal and regulatory requirements. IFRS for SMEs has not been adopted in Portugal.

Based on available information, IFRS as endorsed by the European Union are adopted and required for use by public interest entities in Portugal.

Current Status: Adopted

Relevant Organizations

• Comissão de Normalização Contabilística (CNC)
• Comissão do Mercado de Valores Mobiliários (CMVM)
• Ordem Dos Contabilistas Certificados (OCC)
• Ordem dos Revisores Oficials de Contas (OROC)

Relevant Legislation

• Decree Law No. 148/2015
• Decree Law No. 134/2012
• Decree Law No. 98/2015
• Decree Law No. 140/2015
• Decree Law No. 139/2015
• Ministry of Finance, Ordinance No. 310/2009
• European Commission (EC) Directive 2014/56/EU
• Accounting Directive 2013/34/EU

Relevant Publications

• Accountancy Europe (AE), Definition of Public Interest Entities in Europe - Accountancy Europe, 2017.
• AE, Structure and Organization of the Accountancy Profession – Key Features: Portugal, 2020.
• KPMG, EU Audit Legislation in Portugal, September 2015.
• IFIAR, Member Profile: Portugal, 2018.
• IFRS Foundation, IFRS Application Around the World, Jurisdictional Profile: Portugal, July 2016.
• OCC, SMO Action Plan, January 2017.
• OROC, SMO Action Plan, March 2019.